BOUDIN, Chief Judge.
James R. Fiori won a jury verdict against Truck Drivers Local 170 ("Local 170" or "the union"), a Massachusetts branch of the International Brotherhood of Teamsters ("Teamsters"). Fiori was awarded damages on two different claims but only the libel award, in the amount of $150,000 (as reduced by the judge) is challenged by the union on this appeal. The background events are largely undisputed.
On May 2, 1991, while working for Tresca Brothers...
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